Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Imposition of penalty - delay in deposit of TDS - The Railways should have been conscious of its statutory obligations - penalty reduced to 05% of TDS amount.
Imposition of penalty - delay in deposit of TDS - The Railways should have been conscious of its statutory obligations - penalty reduced to 05% of TDS amount.
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